Citigroup Inc. Settles Potential Civil Liability for Apparent Violations of Multiple Sanctions Programs

September 3, 2014

Mentioned Suspect Entities & Suppliers: 

Related Country: 

  • Malaysia
  • Hong Kong

Citigroup Inc. (Citigroup), New York, New York, has agreed to remit $217,841 to settle potential civil liability for eight apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR), the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598 (FNKSR), or the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR).

Between April 2, 2009, and November 16, 2009, Citigroup Trade Services Malaysia (Citi Penang) processed four export bill collection applications totaling $638,074.15 on behalf of Citibank N.A. (Citibank), Hong Kong that involved the shipment of goods to Iran, and in two of those instances the Islamic Republic of Iran Shipping Lines (IRISL), which OFAC designated on September 10, 2008, pursuant to Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” Although the bank had documentation in its possession related to the export bill collections that contained references to Iran and IRISL, Citi Penang operators did not review or screen the bills of lading, certificates of origin, or shipment advice which contained the references to Iran and/or IRISL.

Separately, on February 9, 2010, January 12, 2011, March 8, 2011, and October 29, 2012,Citibank processed four funds transfers totaling $133,786.73 involving entities appearing on OFAC’s List of Specially Designated Nationals and Blocked Persons (the SDN List). Citibank’s interdiction software did not identify references to the sanctioned parties in the payment instructions, and the bank processed the payments straight through without manual intervention. For example, Citibank received and processed a funds transfer initiated by a third-country financial institution’s customer, Higher Institute for Applied Science and Technology. Although the SDN List contained an entry for an entity named Higher Institute of Applied Science and Technology at the time of the transaction, Citibank did not stop the payment.

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